Chiles v. Salazar

Speech, Conduct, and Viewpoint Discrimination in Professional Regulation

At issue is whether states may categorically prohibit certain therapeutic interventions for minors under their authority to regulate professional medical practice, or whether those prohibitions amount to viewpoint-based restrictions on speech. The Court’s classification of the challenged statute—speech or conduct—is the decisive doctrinal hinge.

Key Takeaways from Oral Argument

Petitioner's Position

The statute is a content-and-viewpoint-based restriction that broadly forbids certain counseling goals for minors (SOCE/GICE). Under this framing the law triggers strict scrutiny as a speech restriction.

Government / Respondent

Colorado frames the statute as regulation of medical/professional conduct—harmful treatment—so it should be tested under the state's authority to protect minors and professional standards rather than as pure speech.

Solicitor General

The SG highlighted viewpoint concerns and questioned whether the record supports a categorical ban on licensed, non-aversive talk therapy for minors—suggesting the evidentiary fit is essential under heightened review.

Judicial Fault Lines

Justices focused on whether the activity is only speech (protected) or speech integral to medical conduct (regulable), and repeatedly returned to viewpoint-discrimination hypotheticals.

Why Viewpoint Discrimination Matters

If the statute is a viewpoint-based restriction—permitting counseling that advances one stance (identity-affirming) while forbidding counseling that advances the opposite (assistance aimed at changing identity)—it faces strict scrutiny. Under that standard the state must show a compelling interest and narrow tailoring specific to the practice banned.

Colorado's counterargument treats the statute as professional-practice regulation directed at harmful treatments; that framing invites deferential review rooted in states' police powers and professional licensure regimes.

The Speech vs. Conduct Distinction

The transcript revolves around one question: is the banned activity speech protected by the First Amendment, or is it medical conduct that the state may regulate? If the Court treats the activity as conduct, professional-regulation precedents and public-health rationales carry substantial weight. If the Court treats the activity as speech, classic First Amendment protections apply.

Petitioner — Core Characterization

Chiles argues the practice at issue is private, word-based counseling—no physical procedures, hormones, or surgeries—and thus constitutes speech. The claimed target is the therapist's purpose: changing identity or orientation, which is a content- and viewpoint-based constraint.

Legal significance: If accepted, the statute triggers strict scrutiny as viewpoint discrimination.

Petitioner also stresses the consensual nature of therapy (parental involvement for minors) and warns that banning options requested by patients can itself produce harms.

Respondent — Core Characterization

Colorado argues the law targets harmful treatment practices and is therefore an exercise of the state's traditional authority to regulate healthcare and protect minors. Speech is presented as incidental to the regulated professional conduct.

Doctrinal hook: Under the "speech-integral-to-conduct" doctrine, a state may regulate professional practices even where communication is part of the service, provided the regulation targets conduct.

Colorado emphasizes fiduciary duties, professional standards, and the state's interest in preventing harm to vulnerable minors.

Patient Protection and Vulnerability

Petitioner — Autonomy & Access

Petitioner argues that removing therapeutic options sought by patients (and parents) undermines autonomy and may harm minors who seek exploratory or non-affirming therapy.

Policy point: A categorical ban can eliminate clinically appropriate options for some patients.

Respondent — Vulnerability & State Interest

The state stresses minors' vulnerability and argues a compelling interest in protecting children from treatments shown to be ineffective or harmful, including elevated suicidality associated with certain conversion practices.

Legal doctrine: Courts often allow broader regulation when children's health and safety are at stake.

Professional Standards and Accountability

Petitioner — Disagreement Means Scrutiny

Where medical opinion is contested or unsettled, petitioner argues the state cannot ban viewpoints. Without a clear professional consensus that the specific practice is harmful, a speech-restrictive law is constitutionally suspect.

Respondent — Licensure, Standards, and Oversight

Licensed professionals operate under state-imposed standards; the First Amendment does not shield practitioners from regulation that polices harmful or ineffective clinical practices.

Several circuits have treated professional speech as more regulable, though the Supreme Court has not fixed the doctrine’s limits.

Competing Standards of Care & Federalism

Petitioner — National First-Amendment Floor

Petitioner argues the First Amendment should prevent a patchwork in which some states ban core therapeutic speech while others allow it—viewpoint protections are national.

Respondent — State-by-State Regulation

Respondent emphasizes traditional state police powers: states can draw different lines about medical standards and child protection without running afoul of federalism constraints.

Therapeutic Goals & Purpose-Based Distinctions

Petitioner — Purpose and Autonomy

Therapy is often goal-driven and sought by patients. Banning therapies whose stated purpose is to change identity interferes with patient self-determination and parental authority for minors.

Viewpoint concern: Allowing affirming therapy while banning change-oriented therapy creates a structural asymmetry.

Respondent — Purpose-Based Safety Line

Colorado draws a purpose-based line: therapy is permitted to the extent it helps cope or reduce distress but is banned where its objective is to change identity. When objective equals harmful practice, the state says regulation targets conduct, not belief.

Evidence of Harm — Fit with the Record

Petitioner — Evidence Gaps

Petitioners and the SG argued much of the cited research addresses adults, aversive techniques, or religious settings—not licensed, non-aversive talk therapy for minors. Under strict scrutiny, they contend the state must show narrow tailoring to identifiable harms.

Respondent — Empirical Basis

Colorado cites peer-reviewed studies (e.g., Green, Turban) and other evidence associating conversion efforts with elevated suicidality and other harms. Professional bodies' statements condemning such practices reinforce the state's risk-based justification.

Historical Pedigree & Equity Roots

Petitioner — Limits on Broad Equitable Remedies

Petitioner points to historical limits on broad equity remedies (Rule 48, "bills of peace") and cautions against expansive remedial power that could undermine First Amendment protections and percolation across circuits.

Respondent — Protective Equity Pedigree

Respondent invokes historical equity tools used to protect vulnerable groups—arguing courts have fashioned broad remedies when necessary to prevent systemic harms and protect minors.

Transcript Signals — Viewpoint & Speech-Integral-to-Conduct

Viewpoint Discrimination

Several Justices raised hypotheticals that highlight asymmetry: permitting identity-affirming therapy while banning change-oriented therapy looks like viewpoint discrimination on its face—if the statute is read as targeting the purpose rather than harmful conduct.

Speech-Integral-to-Conduct Line

Other questioning focused on whether speech is inseparable from medical practice. If words are constitutive of a harmful therapeutic intervention, the state argues it may regulate the practice even where communication is the vehicle.

Professional Organizations' Positions

American Psychological Association

The APA concludes that efforts to change sexual orientation or gender identity lack demonstrated efficacy and pose risk of harm. It opposes SOCE/GICE practices for minors.

APA resolution →

American Psychiatric Association

The APA (psychiatry) opposes conversion therapies, citing lack of evidence for efficacy and potential for psychological harm.

APA (Psychiatry) →

American Academy of Child & Adolescent Psychiatry

AACAP warns against conversion practices for youth and describes them as interventions intended to alter sexual orientation or gender expression.

AACAP policy →

Doctrinal Pathways the Court Might Adopt

Practical Doctrinal Outcome Paths

1. Viewpoint-based speech restriction → strict scrutiny.

If the Court treats the law as viewpoint-based, Colorado must show a compelling interest and narrow tailoring. The transcript records skepticism about whether the record meets that burden for licensed, non-aversive talk therapy to minors.

2. Regulation of medical conduct → deferential review.

If the law is a professional-practice regulation aimed at preventing harmful treatments, the state has a substantially stronger path to uphold the ban under its police powers and licensure authority.

3. Hybrid / narrow rule.

The Court might adopt a tailored rule distinguishing speech-only counseling from speech-integrated medical procedures, limiting the decision’s scope and preserving space for state regulation of medicalized interventions.

How the Transcript Uses Professional Positions

Respondents' Reliance

Colorado invoked studies and institutional statements to justify the statute as a health-and-safety regulation aimed at preventing documented harms.

Petitioner & SG Pushback

Petitioner and the Solicitor General challenged whether the record ties those harms to the specific practice at issue (licensed, non-aversive talk therapy for minors). Under a strict-scrutiny framework, they argued the state’s evidence is insufficiently tailored.

Central Question

The dispositive question is classification: Does Colorado’s statute regulate speech (triggering strict First Amendment review) or professional medical conduct (subject to deference under state police powers)? The Court’s answer will determine both the applicable test and the evidentiary showing required to uphold or invalidate the ban.

Analytical Summary

The oral argument centered on the speech/conduct distinction and the evidentiary fit between professional consensus and the specific practice before the Court. Professional associations provide institutional support for state regulation, but petitioner and the SG pressed that the record does not demonstrate the necessary direct causation for licensing a categorical speech ban on licensed, non-aversive talk therapy aimed at minors.

Watch for a narrow rule that differentiates speech-only counseling from speech-integrated medical procedures; the Court may favor a tailored approach that protects conversational therapies while allowing states to regulate medicalized or demonstrably harmful practices.

Citations & Source Guidance

Oral Argument: Chiles v. Salazar, No. 24-539, Supreme Court oral-argument transcript (Oct. 7, 2025). See transcript for Justice questioning on viewpoint discrimination and the speech/conduct framing.

Professional positions: American Psychological Association (SOCE/GICE resolutions), American Psychiatric Association (position on conversion therapy), American Academy of Child & Adolescent Psychiatry (policy statements).